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Transparency & privacy

Privacy policy

This policy applies to the Assimilation Protocol app on iPhone and iPad and to its accompanying website. App processing and website visits are described separately.

1. Controller

Carsten Freitag
Auf dem Kirchstieg 37
21339 Lüneburg
Germany

Email: carstenfreitag@web.de

2. Processing in the app

The app does not require an account. It does not transmit game, usage or device data to the developer or to servers operated by the developer. It contains no advertising, tracking or external analytics or crash SDKs.

The following information is processed locally in the app's protected storage to provide game features:

  • player names and app settings
  • your programs, including names, authors, comments and code
  • friend programs you choose to import
  • local high scores and match statistics
  • onboarding progress and discarded library entries
  • temporary match, analysis and replay data during use

This processing is necessary to provide the app functions you request (Article 6(1)(b) GDPR). Technically necessary storage on the device does not require separate consent under Section 25(2)(2) TDDDG (Germany). We do not ask for blanket acceptance of this policy.

3. Sharing and device access in the app

Programs are shared only when you explicitly use the file picker, sharing menu or select a nearby device. For a direct connection, the selected program package and visible device name are transferred in encrypted form between the participating devices. Neither the developer nor its own servers receive a copy. An exported package may include the program name, author, notes and code.

The app needs local-network permission to find nearby devices. A connection is made only after selection or confirmation and can be disconnected in the app. It does not access the camera, microphone, photos, contacts, location, health data or advertising identifier. It does not record audio.

4. Storage and deletion in the app

You can remove your own and imported friend programs in the app, delete high scores individually or all at once, and change settings. Deleting the app removes its local data from the device. Depending on system settings, app data may be included in a device or iCloud backup managed by Apple; the developer cannot access those backups.

Local data resides in the app container protected by iOS or iPadOS. Program analysis and suggestions are calculated locally from game code. There is no profiling or automated decision-making about people within the meaning of Article 22 GDPR.

5. Apple services

Downloads, the App Store product page, any purchase processing, optional system backups and diagnostics provided by Apple are subject to Apple's privacy policy. The app does not integrate an interface for the developer to retrieve those data.

6. Website hosting and delivery

This website is hosted through ChatGPT Sites. OpenAI Ireland Limited processes data on our behalf as a hosting provider where this is necessary to deliver, maintain, stabilize and secure the published website. OpenAI may use the technical providers listed in its current sub-processor list, including Cloudflare.

Access data may include the IP address, date and time, requested URL, referrer, browser and device details, and technical error or security information. The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is the secure, stable and reliable operation of this website.

Further details are available in the ChatGPT Sites Data Processing Addendum and OpenAI sub-processor list.

7. Strictly necessary website security cookie

The Cloudflare security service used by the hosting infrastructure currently sets the __cf_bm cookie when this website is loaded. It helps detect and block automated malicious traffic and is technically necessary for that protection. Cloudflare states that it contains encrypted information used to calculate a bot score, is separate for each visited site and expires after 30 minutes of continuous inactivity.

Device access is based on Section 25(2)(2) TDDDG (Germany), and related personal-data processing is based on Article 6(1)(f) GDPR. Our legitimate interest is preventing abuse and operating the site securely. See the Cloudflare cookie documentation for technical details.

8. No website tracking and currently no consent banner

The Assimilation Protocol website does not use its own analytics, advertising or marketing cookies, tracking pixels or embedded third-party videos. The cookie described above is used exclusively for technical security. We therefore do not currently request consent through a cookie banner.

If analytics, marketing or embedded video services are added later, they will be reviewed before activation. This policy will be updated and, where required, those services will load only after valid consent.

9. No transfer of app data to the website

This website is currently an information and documentation service. It has no user accounts, contact form, upload feature or active forum. Programs, game progress, settings, friend programs and local leaderboard entries from Assimilation Protocol are not transferred to this website.

10. Contact by email

If you contact us voluntarily by email, we process your sender address, message and necessary metadata. Article 6(1)(b) GDPR applies to contractual or pre-contractual requests; otherwise Article 6(1)(f) GDPR applies based on our interest in responding. Messages are deleted once the request is resolved unless statutory retention duties apply.

11. Website recipients, retention and transfers

Recipients of technical data are OpenAI Ireland Limited and the sub-processors used for ChatGPT Sites. Technical data is kept only as long as required for operation, security, error analysis and abuse prevention, or where law requires longer retention.

Where data is processed outside the European Economic Area, transfers are made under the applicable ChatGPT Sites data-processing terms using an adequacy decision or appropriate safeguards such as Standard Contractual Clauses.

12. Your rights

  • Access to personal data being processed
  • Correction of inaccurate data
  • Erasure or restriction of processing
  • Objection to processing based on legitimate interests
  • Data portability where its requirements apply
  • Withdrawal of consent with future effect

Send a message to the email address above to exercise these rights.

The developer cannot identify, retrieve or remotely delete data held only on your device by the app. You can manage those data using the in-app functions described above.

13. Right to complain

You may lodge a complaint with a data-protection authority. The State Commissioner for Data Protection of Lower Saxony is the authority for the controller's place of establishment.

14. Changes

This policy will be updated when functionality, hosting, processing activities or legal requirements change.

Last updated: September 17, 2026

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